RAJESH JALAN,DHANBAD vs. DCIT/ACIT, CIRCLE-1, DHANBAD

The appeal of the assessee is allowed in full

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

7,40,000/- made under Section 68 of the Act. 8. Addition under Section 69A of the Act ₹20,86,500/- (Introduction

ADHUNIK AKSHAT UDYOG PVT. LTD.,,DUMKA vs. ACIT, CIRCLE-3(1), DEOGHAR

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.163/Ran/2025 Assessment Year: 2012-13 Adhunik Akshat Udyog Pvt. Ltd……………............................……….……Appellant Industrial Area, Babupur, Muffasil Thana Dumka, Jharkhand – 814101. [Pan: Aabca4896Q] Vs. Acit, Circle-3(1), Deoghar…...…..….…..….........……........……...…..…..Respondent Appearances By: Shri Sushil Pransukha, Ar, Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 28, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Nfac, Delhi [“Cit(A)”] Dated 11.03.2025 Under Section 250 Of The Income-Tax Act, 1961 (The “Act”) For The Assessment Year 2012–13. 2. Facts Of The Case Are That The Assessee Company Filed Its Return Of Income For Ay 2012–13 Declaring Total Income Of ₹2,57,551. The Case Was Reopened Under Section 147 On The Ground That The Assessee Had Raised Share Capital & Share Premium From Certain Entities, Whose Financial Capacity & Genuineness Of Investment Remained Unexplained. During Assessment, The Ao Noted That The Assessee Had Introduced Share Capital Of ₹37,50,000 From The Following Four Private Limited Companies:

section 68 of the Act. Accordingly the appeal of the assessee is allowed. 7. In the result, the appeal

M/S ANJENEYE ISPAT LTD.,SARAIKELA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, JAMSHEDPUR, JAMSHEDPUR

In the result the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.74/Ran/2022 Assessment Year: 2008-09 M/S Anjeneya Ispat Ltd.…………….…….…............................……….……Appellant 29, Rain Basera, Sanjay Nagar Colony, Adityapur, Saraikela, Jharkhand – 831013. [Pan: Aagca1031N] Vs. Dcit, Circle-1, Jamshedpur……....….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Ar, Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 11, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A), Jamshedpur (Hereinafter Referred To As “Ld. Cit(A)”) Dated 21.08.2018 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Company Is Engaged In The Manufacturing Of Pig Iron. It Filed Its Return Of Income Declaring Total Income Of ₹1,41,05,250, Which Was Processed Under Section 143(1). During The Assessment Proceedings, The Assessing Officer Noticed That The Assessee Had Received Share Capital & Share Premium Aggregating To ₹3,00,00,000 During The Relevant Previous Year. The Assessing Officer Issued Notices Under Sections 142(1) & 148 Requiring The Assessee To Furnish Complete Details Of The Share Applicants, Including Identity, Creditworthiness & Genuineness Of The Transactions. In Response, The Assessee Furnished Complete Details In Respect Of The Share Capital/Share Premium Received From The Following Parties:

section 68 of the Act relating to “source of source” introduced by the Finance Act, 2012 is prospective and applicable only from AY 2013–14 onwards. Accordingly, for the year under consideration, the assessee was not required to explain the source of the source. Reliance was placed on decision of the Hon’ble Bombay High Court

M/S MANIKARAN POWER LTD,RANCHI vs. ACIT, CIRCLE-2, RANCHI

In the result, the appeal of the assessee in ITA No

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayit(Ss)A No. 01/Ran/2025 (Assessment Year: 2022-23) A.C.I.T., Manikaran Power Limited, Central Circle-2, Manikaran Tower, Kilburn Colony, Vs. Ranchi. P.O. Hinoo, Ranchi-834002 (Jharkhand) J.C.I.T. (In Situ), Pan No. Aaecm 4555 F Ranchi. Revenue/ Appellant Respondent/ Assessee Manikaran Power Limited, A.C.I.T., Manikaran Tower, Kilburn Colony, Central Circle-2, Vs. P.O. Hinoo, Ranchi-834002 Ranchi. (Jharkhand) Pan No. Aaecm 4555 F Revenue/ Appellant Respondent/ Assessee

Section 68 of the Act. The ld. AR had also placed before us the copy of the purchase register as also the sales register to show that the quantity of purchases and the quantity of sales were fully tallied. It was a further submission that in respect of the revenue's appeal, the ld. CIT(A) has given

KAMESHWAR ALLOYS AND STEELS PVT. LTD.,KOLKATA vs. ACIT, CENTRAL CIRCLE-1, RANCHI

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.49/Ran/2024 Assessment Year: 2014-15 Kameshwar Alloys & Steels Pvt. Ltd….…............................……….……Appellant 128/3, Hazra Road, Bhawanipur, Kol-700026.. [Pan: Aadck6558K] Vs. Acit, Cc-1, Ranchi.................……….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Md. Shadab Ahmed, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 16, 2025 Date Of Pronouncing The Order : January 14, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 05.02.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Company, Filed Its Return Of Income For The Assessment Year Under Consideration. The Case Was Originally Selected For Scrutiny On The Issue Of Share Capital & Share Premium Received During The Year. The Assessing Officer Completed The Assessment Ex Parte Under Section 144 Of The Income-Tax Act, 1961, On The Ground Of Alleged Non-Compliance & Made An Addition Of ₹2,00,00,000 Being Share Capital & Share Premium Received From Various Companies, Treating The Same As Unexplained Under Section 68 Of The Act. Subsequently, A Search & Seizure Operation Under

section 68 stands duly justified by the assessee with help of the documents attached herein and that no adverse comment has been made by the lower authorities on the same nor there is any link to show that the assessee has routed back its own unaccounted funds. 7

M/S ANJENEYA ISPAT LTD.,SARAIKELA vs. DEPUTY COMMISSIONE OF INCOME TAX, CIRCELE-1, JAMSHEDPUR, JAMSHEDPUR

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.75/Ran/2022 Assessment Year: 2009-10 M/S Anjeneya Ispat Ltd.…………….…….…............................……….……Appellant 29, Rain Basera, Sanjay Nagar Colony, Adityapur, Saraikela, Jharkhand- 831013. [Pan: Aagca1031N] Vs. Dcit, Circle-1, Jamshedpur.….....…..…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Cit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A), Jamshedpur (Hereinafter Referred To As “Cit(A)”) Dated 25.09.2017 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2019–20 Declaring A Total Income Of ₹62,64,116. The Case Was Selected For Complete Scrutiny. During The Relevant Previous Year, A Survey Operation Under Section 133A Of The Income-Tax Act, 1961 Was Conducted At The Business Premises Of The Assessee On 16.02.2019. Subsequently, Statutory Notices Under Sections 143(2) & 142(1) Of The Act Were Issued. In Response Thereto, The Assessee Appeared From Time To Time & Furnished Various Details & Documents As Called For. The Same Were Examined & Discussed By The Assessing Officer During The Course Of Assessment Proceedings. During

section 68 of the Act. In the appellate order, in page No. 7, para (v), the ld. CIT(A) has noted

ACIT,CIRCLE-2(1), HAZARIBAG vs. SANJAY KUMAR UPADHYAY, HAZARIBAG

In the result, the appeal filed by the Revenue is dismissed

Bench: Sri Sanjay Garg & Dr. Manish Borad

Section 68 of the Act. Brief facts relating to the issue are that there was an increase in the capital during the year at Rs. 46,86,305/-. The claim of the assessee was that the source of the same was the amount withdrawn by the assessee from the partnership firm M/s. Baba Baidyanath Constructions where the assessee

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, JAMSHEDPUR, JAMSHEDPUR vs. BENKO TRADERS PRIVATE LIMITED, KOLKATA

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.436/Ran/2024 Assessment Year: 2015-16 Acit, Cc, Jamshedpur…………….…….…............................……….……Appellant Vs. Benko Traders Pvt. Ltd....………...….…..….........……........……...…..…..Respondent 119, 4Th Floor, Block D, White House, Park Stree, Wb – 700016. [Pan: Aabcb1888R] Appearances By: Shri Akshay Ringasia, Ar, Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 07, 2025 Date Of Pronouncing The Order : December 17, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-3, Patna For The Assessment Year 2015–16 Dated 25.09.2024 Passed U/S 250 Of The Income Tax Act (The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income Under Section 139 Of The Act Declaring A Total Income As Nil. The Return Was Processed Under Section 143(1). Subsequently, The Case Was Selected For Scrutiny & An Assessment Under Section 143(3) Was Completed On 28.11.2017 Determining The Total Income At ₹9,88,28,406. Based On Information Received From The Investigation Wing, Mumbai, Relating To Alleged Use Of Stock Exchange Platform (Bse/Nse) For Generating Fictitious Long-Term/Short-Term Capital Gains Through Certain Scripts & Alleged Accommodation Entries, The Assessing Officer Recorded Reasons Under Section 147 Of The Act. A Notice Under Section 148 Was Issued The Assessee Filed Its Return Declaring The Same Income

section 68 of the Act. Doing so results in double addition, which is impermissible in law. While passing the order the ld. CIT(A) correctly appreciated these facts and deleted the addition. We therefore do not find any infirmity in his order. Accordingly, this ground of the Revenue is dismissed. 7

GOLDEN GOENKA COMMERCE PVT. LTD.,,KOLKATA vs. ACIT CIRCLE-2(1),, JAMSHEDPUR

In the result, the appeal filed by the assessee stands allowed

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.11/Ran/2024 Assessment Year: 2011-12 Golden Goenka Commerce Pvt. Ltd. (Earlier Known As Rajgaj Traders Pvt. Ltd.)............................……….……Appellant 25A, S.P Mukherjee Road, 4Th Floor, Bhawanipore, Kol-25, [Pan: Aabcr7503F] Vs. Acit, Circle-2(1), Jamshedpur..…..….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Ar, Appeared On Behalf Of The Appellant. Shri Kumar Pranab, Cit- Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 4, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals) [“Cit(A)”], Dated 21.12.2018, Arising Out Of Assessment Framed Under Section 147 Read With Section 143(3) Of The Income-Tax Act, 1961 (The “Act”) For The Assessment Year 2011–12. 2. The Assessee Has Raised Multiple Grounds, The Sum & Substance Of Which Is That The Learned Cit(A) Erred In Upholding The Addition Of ₹4,73,00,000 Made By The Assessing Officer (“Ao”) Under Section 68 Of The Act Towards Share Capital & Share Premium, Ignoring The Documentary Evidences Placed On Record & Without Conducting Any Independent Enquiry. 3. Brief Facts Of The Case Are That The Assessee Company Filed Its Return Of Income For The Assessment Year 2011–12 Declaring Total Income Of ₹16,67,088. Subsequently, The Case Of The Assessee Was Reopened

7. We have heard the rival submissions and carefully perused the material on record. The core issue before us is whether the assessee has satisfactorily discharged the onus cast upon it under section 68

KROSS LIMITED,ADITYAPUR vs. DCIT, CIRCLE-1, JAMSHEDPUR

Accordingly, ITA No. 98/RAN/2025 is allowed

Bench: the CIT(A) where appeal was dismissed on wrong facts.4. Dissatisfied with the above order, assessee is in appeal before this Tribunal.

section 68 of the Act cannot be made in a year in which no fresh credit has been received. 6. On the other hand, although the learned DR supported the orders of the lower authorities, he could not controvert the factual position that the amount of ₹2,00,00,000/- was received in earlier years and no fresh share

KROSS LIMITED,ADITYAPUR vs. DCIT,CIRCLE-1, JAMSHEDPUR

Accordingly, ITA No. 98/RAN/2025 is allowed

Bench: the CIT(A) where appeal was dismissed on wrong facts.4. Dissatisfied with the above order, assessee is in appeal before this Tribunal.

section 68 of the Act cannot be made in a year in which no fresh credit has been received. 6. On the other hand, although the learned DR supported the orders of the lower authorities, he could not controvert the factual position that the amount of ₹2,00,00,000/- was received in earlier years and no fresh share

ACIT, CIRCLE-3, RANCHI vs. SHRI SUMIT RAMSISARIA, RANCHI

Bench: Shri J.Sudhakar Reddy & Shri S.S.Godara

section 68 of the Act. In view of above we find no reason to interfere in the order of ld. CIT(A). Hence this ground of Revenue is dismissed.” ITA No.222/R/2019 & C.O.12/R/2019 A.Y. 2014-15 ACIT, Cir-3,RAN Vs. Sh Sumit Ramsisaria Page 13 We accordingly find no reason to accept Revenue’s arguments seeking to revive

PARAS KUMAR SARAWGI,GIRIDIH vs. ACIT, C. C., DHANBAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

68 or 69A, excess stock is covered u/s 69 or 69B, construction of Shed/Godown is covered u/s 69B or 69C and advances made to Sundry Parties is covered u/s 69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections

AAKRITI SARAWGI,,GIRIDIH vs. ACIT CENTRAL CIRCLE, DHANBAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

68 or 69A, excess stock is covered u/s 69 or 69B, construction of Shed/Godown is covered u/s 69B or 69C and advances made to Sundry Parties is covered u/s 69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections

SANTOSH KUMAR SARAWGI,GIRIDIH vs. ACIT, C. C., DHANBAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

68 or 69A, excess stock is covered u/s 69 or 69B, construction of Shed/Godown is covered u/s 69B or 69C and advances made to Sundry Parties is covered u/s 69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections

SAMIR KUMAR SARAWGI,GIRIDIH vs. ACIT, C. C., DHANBAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

68 or 69A, excess stock is covered u/s 69 or 69B, construction of Shed/Godown is covered u/s 69B or 69C and advances made to Sundry Parties is covered u/s 69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections

RAJESH BADRI PD. MODI,GIRIDIH vs. ACIT, CENTRAL CIRCLE, DHANBAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

68 or 69A, excess stock is covered u/s 69 or 69B, construction of Shed/Godown is covered u/s 69B or 69C and advances made to Sundry Parties is covered u/s 69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections

KANTA DEVI SARAWGI,GIRIDIH vs. ACIT, C.C., DHANBAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

68 or 69A, excess stock is covered u/s 69 or 69B, construction of Shed/Godown is covered u/s 69B or 69C and advances made to Sundry Parties is covered u/s 69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections

HARISH KUMAR SARAWGI,GIRIDIH vs. ACIT, C.C., DHANBAD

In the result, all the appeals filed by the assessee are allowed

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahayassessment Year: 2021-22

68 or 69A, excess stock is covered u/s 69 or 69B, construction of Shed/Godown is covered u/s 69B or 69C and advances made to Sundry Parties is covered u/s 69, 69B or 69D is like an open ended hypothesis which is not supported by any specific finding that the matter shall fall under which of the specific sections